A front desk manager of a golf resort complained about naked strippers and suspect noises. The Seventh Circuit found no sexual harassment because the manager was not present during these incidents and did not show how her employment was impacted.

The Court found that “Father Nutt’s behavior did not rise to the level of actionable hostile work environment sexual harassment. . . None of the incidents was physically violent or overtly threatening . . . the three isolated incidents which occurred over a nine month period were not so severe or pervasive as to poison LeGrand’s work environment.”

A female plumber was subjected to pornography and crude comments. Her case was dismissed because after she complained to management, the employer took corrective action and there was no significant change in her employment status.

The owner of the Salt Lake City Buzz allegedly made clear in an interview for the GM job that he wanted the GM to provide sexual favors. Three women testified that they were offered the GM job with the understanding that sexual favors would have to be provided. The Tenth Circuit found that a jury could reasonably dismiss the case because the GM applicant was not qualified to be a GM.

A salesperson reported sexual harassment by a supervisor on September 3rd. A company investigation started on September 10th. The harasser was suspended three days later. Case dismissed. The employer was entitled to an affirmative defense because it acted reasonably and there was no tangible employment action.